Introduction

Inteluct Technologies [Limited] ("Inteluct", "we", "us" or "our") respects your privacy and is committed to protecting the personal data of users of our website, mobile application, web application and related digital services.

• This Privacy Policy explains how we collect, use, disclose, store, protect and otherwise process personal data when you:
• visit our website
• download or use the Inteluct application
• create an Inteluct account
• purchase or subscribe to our services
• use our educational and legal-training resources
• participate in assessments or practice examinations
• communicate with us
• contact customer support
• participate in surveys or promotions
• interact with our advertisements or communications; or

otherwise use our services.

This Privacy Policy is intended to comply with applicable Nigerian data-protection requirements, including the Nigeria Data Protection Act 2023 ("NDP Act"), the applicable NDP Act General Application and Implementation Directive 2025 ("GAID"), and other applicable data-protection laws.

The NDP Act establishes the Nigeria Data Protection Commission ("NDPC") as Nigeria's data-protection regulator and applies, among other circumstances, to organisations operating in Nigeria and to certain processing of personal data of persons in Nigeria.

1. Who We Are

• The entity responsible for your personal data is:

Inteluct Technologies Lagos, Nigeria

Email: inteluct@gmail.com

For purposes of applicable Nigerian data-protection law, Inteluct may act as a Data Controller in relation to personal data that we determine the purposes and means of processing.

Where Inteluct processes personal data strictly on behalf of another organisation, Inteluct may act as a Data Processor.

The exact role will depend on the particular service and processing activity.

2. Our Commitment To Privacy

Inteluct is committed to processing personal data in accordance with applicable law and recognised data-protection principles.

• Our approach is based on the following principles:
• lawfulness, fairness and transparency
• purpose limitation
• data minimisation
• accuracy
• storage limitation
• integrity and confidentiality
• accountability; and

appropriate technical and organisational security measures.

These principles are consistent with the data-protection principles recognised by the NDP Act and the NDPC's published privacy framework.

3. WHAT IS PERSONAL DATA?

"Personal data" means information relating to an identified or identifiable individual.

• Depending on how you use Inteluct, personal data may include:
• name
• email address
• telephone number
• username
• password credentials
• date of birth
• gender, where voluntarily provided
• nationality, where relevant
• educational institution
• programme of study
• course or level of study
• graduation information
• student status
• professional information
• profile photograph
• subscription information
• transaction information
• learning activity
• assessment results
• examination practice results
• study preferences
• saved materials
• bookmarks
• notes
• questions submitted to the Platform
• customer-support communications
• survey responses
• device information
• IP address
• browser information
• operating system
• approximate location derived from technical information
• usage information
• cookies and similar identifiers; and

information you voluntarily provide to us.

We seek to collect only information that is reasonably necessary for the purposes for which it is processed.

4. Information We Collect

4.1 Information You Provide Directly

• You may provide information when you:
• create an account
• complete your profile
• subscribe to a plan
• purchase a product
• contact us
• complete a survey
• participate in a promotion
• submit feedback
• communicate with customer support
• participate in an educational programme; or

submit content through the Platform.

• For example, when creating an account, we may collect your:

Name, email address, telephone number, password, institution, programme, level of study and study preferences.

5. Educational And Learning Information

Because Inteluct is an educational technology platform, we may collect information concerning your use of our educational services.

• This may include:
• courses accessed
• questions attempted
• answers submitted
• scores
• assessment results
• practice examination results
• study time
• learning progress
• completed modules
• saved content
• bookmarks
• study preferences
• areas of interest
• performance statistics; and

learning history.

We may use this information to provide and improve personalised learning features.

Where learning analytics are used to make recommendations, those recommendations are intended to support learning and do not constitute professional, academic or legal determinations about you.

6. Account Information

When you register for Inteluct, we may create an account associated with your information.

• Account information may include:
• username
• email address
• password credentials
• profile information
• account preferences
• subscription status
• account activity; and

security information.

Passwords should be stored using appropriate security mechanisms and should not be stored by Inteluct in plain text.

You are responsible for maintaining the confidentiality of your account credentials.

7. Payment Information

When you purchase a subscription or other paid service, payment may be processed through third-party payment providers.

• Depending on the payment method, information processed may include:
• transaction amount
• transaction date
• payment status
• currency
• payment reference
• billing information
• card or bank-related information; and

other information required to process the transaction.

Where payment processing is performed by a third-party provider, Inteluct may not receive or store the full payment-card details.

Payment providers may process personal data according to their own privacy policies and applicable laws.

8. Information Collected Automatically

When you access Inteluct, certain technical information may automatically be collected.

• This may include:
• IP address
• device type
• operating system
• browser type
• application version
• device identifiers
• language settings
• time zone
• access times
• pages or screens viewed
• features used
• referral information
• crash information
• performance information; and

other technical information.

We use this information for security, analytics, troubleshooting and improving the Platform.

9. Cookies

Inteluct may use cookies and similar technologies.

• Cookies may be used for:
• authentication
• account security
• remembering preferences
• maintaining sessions
• analytics
• improving performance
• measuring engagement
• understanding how users interact with the Platform; and

providing relevant communications.

• Cookies may be:

Necessary Cookies

These are required for the Platform to operate properly.

Preference Cookies

These remember settings and preferences.

Analytics Cookies

These help us understand how users interact with the Platform.

Marketing Cookies

Where used, these may assist with advertising or measuring marketing activities.

Where applicable, non-essential cookies will be deployed in accordance with applicable legal requirements and available consent mechanisms.

The NDPC itself recognises cookies and similar technologies as capable of processing website engagement information and states that cookie settings can be managed by users.

10. Why We Collect Personal Data

• Inteluct may process personal data for the following purposes:
• creating and managing user accounts
• providing educational services
• providing subscriptions
• processing payments
• personalising learning experiences
• tracking educational progress
• providing assessments
• providing customer support
• communicating with users
• sending service notifications
• improving Platform functionality
• preventing fraud
• detecting security threats
• maintaining Platform integrity
• conducting analytics
• improving educational content
• developing new products
• complying with legal obligations
• enforcing our Terms of Service
• protecting Inteluct and its users
• resolving disputes
• conducting legitimate business administration
• sending marketing communications where permitted; and

carrying out other purposes disclosed at or before the time information is collected.

11. Lawful Bases For Processing

Depending on the circumstances, Inteluct may rely on one or more lawful bases recognised by applicable law.

• These may include:

11.1 Performance of a Contract

We may process information necessary to provide services you have requested.

• For example, we need certain information to:
• create your account
• provide your subscription
• provide educational content; and

process transactions.

11.2 Consent

Where consent is legally required, we will request it before processing.

You may withdraw consent where applicable.

Withdrawal of consent does not necessarily affect processing lawfully carried out before withdrawal.

11.3 Legal Obligation

We may process personal data where necessary to comply with applicable law or lawful regulatory requirements.

11.4 Legitimate Interests

• Where legally permitted, we may process personal data for legitimate interests, including:
• improving services
• protecting security
• preventing fraud
• maintaining systems
• communicating with users; and

managing our business.

Where relying on legitimate interests, we will consider applicable data-protection requirements and the rights and interests of affected individuals.

11.5 Vital Interests or Public Interest

Where legally applicable, Inteluct may process personal data where necessary to protect vital interests or perform a task carried out in the public interest or under applicable law.

12. Marketing Communications

• Inteluct may send you:
• product updates
• educational announcements
• newsletters
• promotional information
• subscription information
• new-feature announcements
• events; and

other communications.

Where required, we will obtain appropriate consent before sending direct marketing communications.

You may unsubscribe from marketing communications at any time using the unsubscribe mechanism provided or by contacting us.

You may continue to receive essential service communications after opting out of marketing.

13. Personalisation

Inteluct may use information about your interaction with the Platform to personalise your experience.

• For example, we may recommend:
• study materials
• practice questions
• learning topics
• revision activities
• educational resources; or

features relevant to your selected programme or level.

Personalisation does not necessarily mean that Inteluct makes a legally significant automated decision about you.

14. Artificial Intelligence

Some Inteluct products may incorporate artificial intelligence or machine-learning technology.

• AI features may process information that you submit to them, including:
• questions
• prompts
• answers
• educational requests
• learning preferences; and

other information necessary to provide the feature.

AI-generated outputs may not always be accurate.

Users should independently verify important legal, academic or professional information.

Inteluct will not represent AI-generated material as an authoritative statement of Nigerian law merely because it is generated by an automated system.

Where third-party AI providers are used, relevant information may be processed by those providers subject to appropriate contractual and legal safeguards.

15. Ai Training And User Data

Unless otherwise disclosed or permitted by applicable law, Inteluct will not intentionally use identifiable user personal data to train a third-party general-purpose AI model without an appropriate lawful basis.

Where user-generated content may be used for product improvement, we will apply appropriate safeguards and, where required, obtain consent or provide the required notice.

• Where technically and legally appropriate, Inteluct may use aggregated, anonymised or de-identified information for:
• analytics
• research
• product improvement
• educational research
• system testing; and

service development.

16. Who We May Share Personal Data With

Inteluct may disclose personal data to carefully selected third parties where necessary and lawful.

• These may include:

Payment Providers

To process subscriptions and payments.

Cloud and Hosting Providers

To store and operate Platform data.

Analytics Providers

To understand Platform usage and performance.

Communication Providers

To send email, SMS, push notifications or other communications.

Cybersecurity Providers

To protect the Platform and detect security threats.

Customer-Service Providers

To assist with customer enquiries.

Artificial Intelligence Providers

Where necessary to provide specific AI-powered features.

Professional Advisers

Such as lawyers, accountants, auditors or consultants where necessary.

Regulators and Government Authorities

Where required by law or lawful regulatory process.

Corporate Transaction Parties

Where necessary in connection with a merger, acquisition, restructuring, financing or sale of assets, subject to applicable law.

17. Data Processors

Where third parties process personal data on behalf of Inteluct, we will seek to ensure that appropriate contractual, organisational and technical safeguards are implemented.

• Processors may be required to:
• process data only for authorised purposes
• maintain confidentiality
• implement appropriate security measures
• assist Inteluct with data-protection obligations; and

delete or return personal data where appropriate.

18. International Data Transfers

Some Inteluct service providers may operate outside Nigeria.

Accordingly, personal data may be transferred to or accessed from countries outside Nigeria.

Where applicable, Inteluct will implement the safeguards required under Nigerian data-protection law for international transfers.

• These safeguards may include:
• contractual protections
• adequacy mechanisms where applicable
• appropriate transfer safeguards
• regulatory approvals or mechanisms where required; and

other lawful transfer mechanisms.

19. Data Security

• Inteluct takes reasonable steps to protect personal data against:
• unauthorised access
• accidental loss
• unlawful processing
• destruction
• alteration
• disclosure; and

other security risks.

• Security measures may include:
• encryption where appropriate
• access controls
• authentication mechanisms
• secure hosting
• logging and monitoring
• backup systems
• staff confidentiality obligations
• security testing; and

incident-response procedures.

However, no online service can guarantee absolute security.

20. Data Breaches

If Inteluct becomes aware of a personal-data breach, we will assess the incident and take appropriate steps in accordance with applicable law.

Where notification to affected data subjects or the NDPC is legally required, Inteluct will make the required notification within the applicable timeframe.

• Inteluct will also take reasonable steps to:
• contain the incident
• investigate the cause
• assess potential impact
• mitigate harm
• restore affected systems; and

prevent recurrence.

The NDPC maintains a formal privacy-breach reporting mechanism and its 2025 implementation framework addresses breach-management requirements.

21. Data Retention

Inteluct will retain personal data only for as long as reasonably necessary for the purposes for which it was collected or as required by applicable law.

• Retention periods may depend on:
• the nature of the information
• the purpose of processing
• whether you maintain an account
• subscription history
• legal requirements
• dispute-resolution requirements
• accounting requirements
• security requirements; and

legitimate business requirements.

When information is no longer required, we will take reasonable steps to delete, anonymise or securely dispose of it.

22. Account Deletion

You may request deletion of your Inteluct account.

• Depending on applicable law, some information may need to be retained after account deletion, including information necessary for:
• legal compliance
• tax and accounting purposes
• fraud prevention
• security
• dispute resolution
• enforcement of legal rights; or

other lawful purposes.

Where information is retained, we will limit its use to the purpose for which retention is required.

23. Your Data Protection Rights

• Subject to applicable law and relevant limitations, you may have rights including:
• the right to be informed
• the right to request access to personal data
• the right to request correction of inaccurate information
• the right to request deletion
• the right to object to certain processing
• the right to request restriction of processing
• the right to data portability
• the right to withdraw consent where processing is based on consent
• rights concerning automated decision-making where applicable; and

the right to lodge a complaint with the NDPC.

The NDPC expressly recognises data-subject rights and provides mechanisms for privacy complaints and remediation.

24. How To Exercise Your Rights

• To exercise a data-protection right, contact:

Inteluct Privacy Team

Email: inteluct@gmail.com

• Your request should include:
• your name
• email address associated with your account
• the nature of your request
• sufficient information to identify the relevant data; and

any additional information reasonably necessary to verify your identity.

We may need to verify your identity before processing certain requests.

25. Data Subject Access Requests

If you request access to your personal data, Inteluct will process the request in accordance with applicable law.

• Where permitted, we may refuse or limit a request where disclosure would:
• adversely affect another person's rights
• reveal confidential information
• compromise security
• conflict with a legal obligation; or

otherwise fall within a lawful exemption.

Where a request cannot be fully granted, we will explain the applicable reason where legally permitted.

26. Correction Of Personal Data

You may request correction of inaccurate or incomplete personal information.

You may also update certain information directly through your Inteluct account.

We encourage users to maintain accurate and current information.

27. Deletion And Erasure

You may request deletion of personal data where applicable.

However, deletion may not be available where processing or retention is required by law or where another lawful basis for retention applies.

Where deletion is granted, Inteluct will take reasonable steps to delete or anonymise the relevant information within applicable systems, subject to legitimate backups and legal retention requirements.

28. Objection To Processing

You may object to certain processing where you have a lawful right to do so.

For example, you may object to direct marketing.

• You may submit an objection to:

inteluct@gmail.com

Inteluct will assess the objection in accordance with applicable law.

29. Data Portability

Where applicable law provides a right to data portability, you may request certain personal information in a structured, commonly used and machine-readable format.

The scope of this right will depend on applicable law and the relevant circumstances.

30. Automated Decision-Making

• Inteluct may use automated technologies for:
• recommendations
• content personalisation
• fraud detection
• security monitoring
• learning analytics
• technical diagnostics; and

other operational purposes.

Where automated decision-making produces legal or similarly significant effects concerning you, Inteluct will comply with applicable legal requirements concerning such processing.

31. Children And Minors

Inteluct recognises that some students using educational technology may be minors.

We do not knowingly collect or process children's personal data in circumstances prohibited by applicable law.

Where processing children's personal data requires parental or guardian consent, Inteluct will implement appropriate mechanisms where reasonably practicable.

• Parents or guardians who believe that a child has provided personal data contrary to applicable requirements may contact:

inteluct@gmail.com

Where appropriate, Inteluct may delete the relevant information.

32. Student And Educational Institution Data

Where Inteluct provides services to universities, law faculties, training institutions or other educational organisations, additional personal data may be processed.

• This may include:
• student identification information
• institution
• programme
• course
• academic level
• learning activity
• assessment results
• attendance or participation
• institutional account information; and

administrative information.

Where an institution determines the purposes and means of processing, the institution may be the relevant Data Controller and Inteluct may act as a Data Processor.

The applicable institutional agreement will determine the respective responsibilities of Inteluct and the institution.

33. Third-Party Websites

Inteluct may contain links to third-party websites.

This Privacy Policy does not govern third-party websites.

We encourage you to read the privacy policy of every third-party website or service you use.

34. Social Media

Inteluct may maintain social-media accounts or provide social-media integrations.

Information you voluntarily post on public social-media platforms may be visible to others and may be processed according to the relevant platform's privacy policy.

Inteluct does not control the privacy practices of third-party social-media platforms.

35. Marketing And Advertising Partners

Where Inteluct uses advertising or marketing providers, those providers may process certain technical or usage information to measure campaigns or deliver advertisements.

Where required by law, appropriate consent mechanisms will be used.

You may have additional choices through your browser, device or advertising platform.

36. Aggregated And Anonymised Data

Inteluct may create aggregated or anonymized information from personal data.

• Examples include:
• number of users
• general usage statistics
• course completion statistics
• aggregated examination performance
• feature usage
• general learning trends; and

Platform performance statistics.

Where information has been properly anonymized so that individuals cannot reasonably be identified, it may be used for legitimate purposes without being treated as personal data to the extent permitted by applicable law.

37. Research And Product Development

Inteluct may conduct research to improve educational technology.

• Research may involve:
• analysing learning patterns
• evaluating features
• improving question banks
• testing educational methodologies
• improving AI systems; and

developing new products.

Where research involves identifiable personal data, Inteluct will ensure that an appropriate lawful basis and safeguards are in place.

Where reasonably possible, research data will be aggregated, anonymized or de-identified.

38. Legal Disclosures

• Inteluct may disclose personal data where reasonably necessary to:
• comply with a court order
• comply with a lawful government request
• comply with regulatory requirements
• investigate fraud
• protect users
• protect Inteluct's legal rights
• enforce contractual terms
• respond to legal proceedings; or

prevent serious harm.

We will seek to limit disclosures to information reasonably necessary for the relevant purpose.

39. Business Transfers

• If Inteluct is involved in:
• a merger
• acquisition
• restructuring
• financing
• sale of assets
• corporate reorganisation; or

similar transaction,

personal data may be transferred as part of the transaction where legally permitted.

Any such transfer will remain subject to applicable data-protection requirements.

40. Data Protection Officer / Privacy Contact

Inteluct will designate an appropriate privacy or data-protection contact and, where required by applicable law, appoint a Data Protection Officer or engage an appropriate Data Protection Compliance Organisation.

41. Privacy Complaints

If you believe that Inteluct has processed your personal data unlawfully or otherwise violated your privacy rights, please contact us first.

• Complaints may be submitted to:

Inteluct Privacy TeamEmail:inteluct@gmail.com

We will investigate complaints and seek to provide an appropriate response within the applicable legal or reasonable timeframe.

42. Complaint To The Nigeria Data Protection Commission

• If you are dissatisfied with Inteluct's response, or where otherwise permitted by law, you may lodge a complaint with the:

Nigeria Data Protection Commission (NDPC)

The NDPC is Nigeria's independent data-protection regulator established under the Nigeria Data Protection Act 2023. Its official website provides information concerning data-subject rights, registration, complaints and privacy-breach reporting.

NDPC Website:Nigeria Data Protection Commission

43. Data Protection Impact Assessments

Inteluct may conduct a Data Protection Impact Assessment ("DPIA") where required by applicable law or where a processing activity is likely to present significant risks to the rights and freedoms of data subjects.

• This may be particularly relevant to:
• artificial intelligence
• profiling
• large-scale processing
• children's data
• sensitive personal data
• behavioural analytics
• automated decision-making; and

other high-risk processing activities.

The NDPC's 2025 GAID includes specific DPIA guidance and a DPIA framework.

44. Sensitive Personal Data

Inteluct generally does not require users to submit sensitive personal data unless specifically necessary for a particular service.

Users should not submit sensitive personal information through public discussion areas or ordinary support channels unless expressly requested and authorised.

Where sensitive personal data is processed, Inteluct will implement the safeguards required by applicable law.

45. User-Generated Content

• If you submit:
• comments
• questions
• answers
• feedback
• photographs
• documents
• reviews
• forum posts
• AI prompts; or

other material,

Inteluct may process the information for the purposes described in this Privacy Policy and our Terms of Service.

Do not submit another person's personal information unless you have a lawful basis and authority to do so.

46. Confidential Information

Inteluct is an educational technology platform and should not ordinarily be used to submit confidential legal-client information, privileged documents or other highly confidential material unless the relevant Inteluct service expressly provides for such use.

• Users should avoid submitting:
• client confidential information
• passwords
• financial account credentials
• government identification numbers
• confidential employment information; or

other sensitive information

unless necessary and expressly requested.

47. Security Of User Credentials

• Users should:
• create strong passwords
• avoid reusing passwords
• use available multi-factor authentication
• avoid sharing account credentials; and

immediately report suspected account compromise.

Inteluct will not ordinarily request your password by email.

48. Data Protection By Design

Inteluct seeks to incorporate privacy and security considerations into the design and development of its products.

• This may include:
• minimising information collected
• limiting access
• implementing security controls
• anonymising information where appropriate
• establishing retention periods
• evaluating privacy risks; and

considering data-subject rights when introducing new features.

49. Changes To This Privacy Policy

Inteluct may update this Privacy Policy periodically.

• Changes may be made because of:
• changes in law
• regulatory guidance
• new Platform features
• new processing activities
• changes in technology
• changes in our business; or

improvements to our privacy practices.

The updated policy will be published on the Platform with a revised "Last Updated" date.

Where required by law, Inteluct will provide additional notice or obtain consent before implementing material changes.

50. Retention Of Previous Versions

Inteluct may maintain previous versions of this Privacy Policy for legal, compliance and record-keeping purposes.

51. Governing Law

This Privacy Policy shall be governed by the laws of the Federal Republic of Nigeria, subject to applicable mandatory data-protection rights and requirements.

Where applicable, disputes may be addressed through the mechanisms provided under Nigerian law and applicable regulatory procedures.

52. International Users

Inteluct may provide services to users outside Nigeria.

Where users access Inteluct from another jurisdiction, additional privacy rights may apply depending on the user's location.

Inteluct will comply with applicable laws to the extent they apply to its processing activities.

Nothing in this Privacy Policy is intended to remove a mandatory privacy right available to a user under applicable law.

53. California, Eu, Uk Or Other Foreign Privacy Rights

Where Inteluct becomes subject to foreign privacy legislation because of its operations, user base or processing activities, Inteluct may publish supplementary notices describing those rights.

Where a specific foreign law applies to a particular user, the user's mandatory rights under that law will apply to the extent required.

54. No Sale Of Personal Data

Inteluct does not intend to sell users' personal data as a commercial commodity.

Where Inteluct engages third parties for advertising, analytics, payment processing, hosting or other services, those arrangements will be governed by applicable contracts and data-protection requirements.

55. Data Processing Records

Inteluct may maintain appropriate internal records concerning its personal-data processing activities where required by applicable law.

• These records may include:
• categories of data
• purposes of processing
• categories of data subjects
• recipients
• retention periods
• security measures; and

international transfers.

56. Privacy And Security Training

Inteluct may provide privacy and information-security training to employees, contractors and relevant personnel whose activities involve personal data.

Personnel may be subject to confidentiality obligations.

57. Contact Us

• For privacy questions, requests or complaints:

Inteluct Technologies [Limited]

Privacy Email: inteluct@gmail.com

General Email: inteluct@gmail.com

Support Email: inteluct@gmail.com

Registered Office:Lagos, Nigeria

58. Acknowledgement

By using Inteluct's website, application or services, you acknowledge that you have had an opportunity to read this Privacy Policy.

Where applicable, you may be asked to provide consent to particular processing activities.

Your continued use of Inteluct does not automatically constitute consent to processing where applicable law requires a separate or express consent mechanism.

59. Important Privacy Notice

Please read this Privacy Policy carefully.

By using Inteluct, you acknowledge that personal data may be processed for the purposes described in this Policy, subject to applicable law and your data-protection rights.

Where Inteluct relies on consent, you may withdraw that consent subject to applicable legal limitations.

• You may exercise applicable data-protection rights by contacting:

[privacy@inteluct.com]

Effective Date: September 24, 2026

Last Updated: September 24, 2026

Inteluct Technologies [Limited]